Slovenia ended its crypto transition on 1 July 2025, and its MiCA law does not mention crypto ATMs
Slovenia implemented MiCA through the ZIUTK act, with the Securities Market Agency as the licensing authority. Providers operating before 2025 could continue only until 1 July 2025 or a licence decision. The first licence was reported in September 2025. The act does not mention crypto ATMs.
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1 Jul 2025
End of the Slovenian transition for existing providers
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EUR 500,000
Highest fine range for medium and large companies under Article 15
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Mentions of crypto ATMs in the ZIUTK act
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Slovenia implemented MiCA through the ZIUTK act, with the Securities Market Agency (ATVP) as the licensing authority.1 Providers operating before 2025 could continue only until 1 July 2025 or a licence decision.1 The first licence was reported in September 2025.3 The act does not mention crypto ATMs.1
Last updated: October 2026
Regulatory Framework
The Act Implementing the Regulation (EU) on Markets in Crypto-Assets (ZIUTK) was adopted by the National Assembly on 23 October 2024 and published in Official Gazette No. 95/2024 on 8 November 2024. It takes effect on the fifteenth day after publication (Article 23).1 ATVP grants and withdraws licences for crypto-asset service providers and supervises them. Banka Slovenije handles e-money token white papers and supervises e-money token issuers.1
Article 21 gives the transition. Providers that offered crypto-asset services under the earlier rules until 30 December 2024, including virtual currency providers under the AML law, could continue until 1 July 2025 or until a licence was granted or refused under Article 63 of MiCA, whichever came first. The simplified procedure in Article 143(6) of MiCA does not apply to them.1 The Ministry of Finance said on 10 July 2026 that the MiCA transitional period had ended on 1 July.2 That date is the EU-wide deadline, and it falls a year after the Slovenian one.
Penalties
The act has no provision aimed at providing services without authorisation. The closest is Article 15, paragraph 1, point 37, which covers failing to meet the conditions for a service provider licence. Fines for legal entities run from EUR 2,500 to EUR 250,000, and from EUR 10,000 to EUR 500,000 for medium and large companies. Sole traders face EUR 2,500 to EUR 150,000, responsible persons EUR 1,250 to EUR 10,000 and individuals EUR 2,500 to EUR 5,000. Serious breaches under Article 16 can bring fines of up to EUR 5 million, or up to 5% of annual turnover for crypto-asset service provider obligations.1
Licences Granted
Bloomberg Adria reported on 26 September 2025 that ATVP had granted the first MiCA licence that month and that more applications were waiting. It also said more than 20 foreign providers could offer crypto trading services in Slovenia.3 The text reviewed does not name the licensee. The ATVP register could not be opened, so the number of Slovenian licence holders on 8 October 2026 is not confirmed.
Crypto ATMs
The ZIUTK act, the Ministry of Finance notice and the licence report reviewed do not mention ATMs or machines.1,2,3 The sources do not say whether a machine operator needs the exchange service authorisation or what ATVP's position on machines is.
What Is Not Known
The AML rules for providers, including the registration under the AML law that existed before MiCA, were not reviewed, and neither were ATVP guidance, fees and processing times. Whether the act's transitional rule has been amended since 2024 was not checked. The first licensee, the number of licence holders and the treatment of cash at machines are open questions for Slovenian counsel and ATVP.
Sources and references
1. Zakon o izvajanju Uredbe (EU) o trgih kriptosredstev (ZIUTK), Uradni list RS, No. 95/2024, 8 November 2024 (PRIMARY, accessed 8 October 2026) | uradni-list.si
2. Ministry of Finance of Slovenia, Financial Friday: the European regulation on markets in crypto-assets, 10 July 2026 (PRIMARY, accessed 8 October 2026) | gov.si
3. Bloomberg Adria Slovenia, ATVP issued the first MiCA licence, more are in the queue, 26 September 2025 (SECONDARY, accessed 8 October 2026) | si.bloombergadria.com
Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Rules may change; always consult specialised local legal counsel and confirm the current position with the Securities Market Agency of Slovenia before considering market entry.